On July 28, 2010 a
Motion,Ex Parte
was filed
involving a dispute between
Sea Coast National Bank,
and
City Of Port St Lucie,
Foster, Kevin,
Mackin, Thomas,
Mackin, Yvonne,
Unk Sp Kevin Foster,
Unk Sp Yvonne Mackin,
for NONHOMESTD MF $50,001-$249,999
in the District Court of St. Lucie County.
Preview
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR ST. LUCIE COUNTY, FLORIDA
SEACOAST NATIONAL BANK, fi/k/a CASE NO,: 562010CA004087
FIRST NATIONAL BANK AND TRUST
COMPANY OF THE TREASURE COAST,
Plaintiff, JUDGE: Senior Judge
vs.
KEVIN D. FOSTER, a/k/a KEVIN FOSTER;
YVONNE MACKIN; THOMAS J. MACKIN,
SR.; THE UNKNOWN SPOUSE OF KEVIN
D. FOSTER, a/k/a KEVIN FOSTER; THE
UNKNOWN SPOUSE OF YVONNE MACKIN;
CITY OF PORT ST. LUCIE; JOHN DOE,
100
er
UNKNOWN TENANT; AND JANE DOE, 3
UNKNOWN TENANT, the names being =3
fictitious to account for parties in possession, Sow
es
Defendants, a =o.
/
DEFENDANTS’ MOTION FOR EXTENSION OF TIME
TO FILE RESPONSE TO COMPLAINT
COME NOW, the Defendants, KEVIN D. FOSTER, a/k/a KEVIN FOSTER, YVONNE
MACKIN, and THOMAS J. MACKIN, SR., by and through undersigned counsel, and hereby file
this Motion for Extension of Time to File Response to Complaint, and as grounds, therefore,
state as follows:
1. The undersigned counsel has just been retained by the Defendants.
2. The undersigned counsel has not had sufficient time to review the Complaint and other
pleadings filed in this case.wy
3. The undersigned counsel requests an extension of time in which to adequately prepare
a response to the Complaint and review the pleadings.
4. This request is not made for purposes of delay or harassment.
5. An extension of thirty (30) days, through and until September 18, 2010, would not
prejudice the parties.
WHEREFORE, the Defendants, KEVIN D. FOSTER, a/k/a KEVIN FOSTER, YVONNE
MACKIN, and THOMAS J. MACKIN, SR., respectfully requests an extension of thirty (30)
days, through and until September 17, 2010, in which to file a response to Complaint in this
cause, and any such further relief as this Court deems just and proper.
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
sent via regular U.S. Mail to Edmond Alonzo, III, Esq., Alonzo Law Offices, P.A., 217 Avenue
A, Fort Pierce, FL 34950 on this _/ gt aay of August, 2010.
GRAZI & GIANINO, LLP
217 East Ocean Boulevard
P.O. Drawer 2846
Stuart, FL 34995-2846
Phone: (772) 286-0200
Fax: (772) 286-4789
-2-
Preview
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA SEACOAST NATIONAL BANK, fi/k/a CASE NO,: 562010CA004087 FIRST NATIONAL BANK AND TRUST COMPANY OF THE TREASURE COAST, Plaintiff, JUDGE: Senior Judge vs. KEVIN D. FOSTER, a/k/a KEVIN FOSTER; YVONNE MACKIN; THOMAS J. MACKIN, SR.; THE UNKNOWN SPOUSE OF KEVIN D. FOSTER, a/k/a KEVIN FOSTER; THE UNKNOWN SPOUSE OF YVONNE MACKIN; CITY OF PORT ST. LUCIE; JOHN DOE, 100 er UNKNOWN TENANT; AND JANE DOE, 3 UNKNOWN TENANT, the names being =3 fictitious to account for parties in possession, Sow es Defendants, a =o. / DEFENDANTS’ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT COME NOW, the Defendants, KEVIN D. FOSTER, a/k/a KEVIN FOSTER, YVONNE MACKIN, and THOMAS J. MACKIN, SR., by and through undersigned counsel, and hereby file this Motion for Extension of Time to File Response to Complaint, and as grounds, therefore, state as follows: 1. The undersigned counsel has just been retained by the Defendants. 2. The undersigned counsel has not had sufficient time to review the Complaint and other pleadings filed in this case.wy 3. The undersigned counsel requests an extension of time in which to adequately prepare a response to the Complaint and review the pleadings. 4. This request is not made for purposes of delay or harassment. 5. An extension of thirty (30) days, through and until September 18, 2010, would not prejudice the parties. WHEREFORE, the Defendants, KEVIN D. FOSTER, a/k/a KEVIN FOSTER, YVONNE MACKIN, and THOMAS J. MACKIN, SR., respectfully requests an extension of thirty (30) days, through and until September 17, 2010, in which to file a response to Complaint in this cause, and any such further relief as this Court deems just and proper. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent via regular U.S. Mail to Edmond Alonzo, III, Esq., Alonzo Law Offices, P.A., 217 Avenue A, Fort Pierce, FL 34950 on this _/ gt aay of August, 2010. GRAZI & GIANINO, LLP 217 East Ocean Boulevard P.O. Drawer 2846 Stuart, FL 34995-2846 Phone: (772) 286-0200 Fax: (772) 286-4789 -2-